European Commission CAP Reform
Proposals 2014-2020 – Consultation
Report
Contents
Page 1
Page 2
Page 3 - 4
Page 4
Page 5
Page 6 - 7
Page 7 - 13
Page 13 - 14
Page 14 – 17
Page 17 -18
Page 18 – 19
Page 19
Page 20
Title Page
Contents
1 - Acknowledgements
2 - Executive Summary
3 - Introduction
4 - General analysis of responses
4.1 – Direct Payments Main Findings
4.2 - Direct payments - Analysis of the questions inviting
comments
4.3 – Rural Development Main Findings
4.4 - Rural Development - Analysis of the questions inviting
comments
4.5 – Horizontal Regulation Main Findings
4.6 - Finance and Control - Analysis of the questions inviting
comments
5 – Conclusion
6 – Feedback
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1 - Acknowledgements – There was a good response to the Scottish Government’s
consultation on the European Commission’s CAP reform proposals for 2014 – 2020.
The number of responses was higher than for previous Scottish Government
consultations on the CAP. Responses reflected the nature and breadth of the varied
interests within Scottish land use management. They reflected the views of
individuals and organisations concerned with farming, the environment, renewable
energy, rural communities and the fabric of life associated with land use in Scotland.
The Scottish Government would like to thank all those individuals and organisations
who took the time to respond to the consultation. The Scottish Government would
also like to thank its rural research division (RESAS) for its advice on this
consultation.
2 - Executive Summary - Responses to each of the 3 main EC CAP Reform
proposals, that is the Direct Payments, the Rural Development and the Finance and
Control (Horizontal) Regulations, tended to support Scottish Government policy and
its negotiating position on CAP reform. Many comments also confirmed the Scottish
Government’s understanding about where stakeholders stood on certain issues.
There were a number of recurring themes, for example:
Direct Payments
• concern about maintaining food production while, at the same time,
supporting sustainable production and ensuring a quick transition to nonhistoric criteria for payment;
• the importance of Less Favoured Areas within Scotland;
• the need to consider variation in land quality in future payments;
• environmental and biodiversity concerns reflect the need to consider a land
use strategy in Scotland which takes account of both market and non-market
outcomes;
• whilst there was reaction against using Pillar 1 funds for “greening” there was
also a degree of support for the greening concept from a wide range of
interests;
• support should focus more on the outcome of activities, not on the activities
themselves;
• support for new entrants to farming is important and should not be restricted
by an arbitrary age limit; and
• access to entitlements is complicated and needs to be considered carefully to
ensure good access.
Rural Development
• Needs to be inclusive and the focus widened beyond just purely agriculture
orientated activities, to encompass other aspects of the rural environment.
• Emphasis should be on local initiative, locally set priorities, strengthening rural
development and sustainability in all its aspects.
• Member State should be able to decide options based on national priorities.
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Finance and Control
• Need to maintain ability to receive payments in Euros.
• Broad support for expanding online systems.
• Calls for more proportionate cross compliance penalties – either by greater
use of warning letters for minor offences or stricter sanctions for breaches
which cause environmental damage.
3 - Introduction – On 12 October 2011, the European Commission published its
draft proposals for the future Common Agricultural Policy (CAP) for the period 20142020. The consultation sought views on the Commission’s proposals. There will be
further stakeholder engagement and a further consultation on how the new CAP
should be implemented in Scotland, after the main regulations have been agreed
and when the detailed implementing rules are known.
The CAP provides the main forms of support to land-based sectors across Europe.
It has undergone a number of changes over the years, most recently in the Health
Check (mid term review) in 2009.
These latest proposals from the Commission set out a completely new framework for
Pillar 1 Direct Payments which will see major differences in the way this support is
allocated in future. The draft regulations also propose revisions to the various
market measures and make changes to the Pillar 2 Rural Development Regulation
which provides the basis for the Scotland Rural Development Programme (SRDP).
Previous Scottish Government consultations on the CAP Health Check and for the
Brian Pack Inquiry have provided us with a good understanding of the main positions
held by stakeholders.
This time, the Scottish Government decided to use Questback to structure the
consultation. Questback is an on-line survey-type questionnaire and is rather
different to the usual written consultations the Scottish Government has used in the
past. It uses tick box responses together with a number of boxes for additional
comments. Using Questback helped the Scottish Government monitor views
throughout the 12 week consultation period thereby informing its negotiating position
in early discussions in Europe.
The consultation was divided into three separate consultations because of the scale
of the CAP reform proposals. This division was aimed at making the consultation
more manageable and acknowledged that not all stakeholders would have an
interest in all three proposals. The three consultations were:
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•
•
Consultation 1: Direct Payments which at present in Scotland consist of the
Single Farm Payment (SFP) and Scottish Beef Scheme (SBS):
Consultation 2: Rural Development which provides the basis for the Scotland
Rural Development Programme (SRDP) including the Less Favoured Area
Support Scheme (LFASS)
Consultation 3: Finance & Control (Horizontal) issues common to both Direct
Payments and Rural Development:
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4 - General analysis of Responses –
Each of the three consultations contained a series of questions on specific aspects
of the Commission’s proposals. In addition, comment boxes followed some
questions where a more in-depth view was needed.
The number of responses received for each of the 3 regulations covered by the
consultation was:
o Direct Payments – 212 responses (198 electronic + 14 hard copy), of which
79.3% were from individuals and 20.7% were from organisations.
o Rural Development – 79 responses (71 electronic + 8 hard copy), of which
50.7% were from individuals and 49.3% were from organisations.
o Finance and Control– 67 responses (58 electronic + 9 hard copy), of which
55.2% were from individuals and 44.8% were from organisations.
The issues raised in the hard copy responses were considered alongside the
comments given in Questback. The majority of those who responded using
Questback responded to all of the tick box questions. Not all respondents added
comments in the comment boxes. The responses have been analysed as follows:
1) the results from the tick box questions on specific aspects of the reforms have
been assessed and the main findings are given below;
2) the additional views that were provided in the comment boxes have also been
assessed.
The following 3 sections cover the analysis of the responses to the consultations on
the Direct Payments (4.1 & 4.2); Rural Development (4.3 & 4.4); and Finance and
Control (4.5 & 4.6) regulations. Each of these sections shows main points arising
from the analysis of the tick box answers (sections 4.1, 4.3 and 4.5) followed by a
summary of the additional comments (sections 4.2, 4.4 and 4.6).
The analysis of tick box questions shown below makes no distinction between
organisational responses and individual responses. The tick box answers were
initially analysed by grouping the number of responses as shown below:
•
•
•
Strongly Agree + Agree responses = “Agree”
Strongly disagree + Disagree responses = “Disagree”
Neither agree/disagree + don’t know responses = “Neutral”
The relative strengths of the answers were then compared. Questions were classed
as having the strongest agreement where they had more than 66% strongly agree
and agree types of responses and in addition, where the number of strongly agree
responses was greater than the number of responses that agreed with the question.
A similar exercise was performed to identify the questions which elicited strongest
disagreement.
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4.1 – Direct Payments Main Findings
There were 212 responses on the Direct Payments Regulation. Of those that
responded using Questback, 150 said their main interest was farming, 30 had
environmental interests with the remainder having either food, forestry, other
business or community group interests.
Strong agreement (More than 66.6% of responses agreeing with question):
•
•
•
•
•
•
•
Minimum activity required for payment = 89%
Scottish National Reserve (NR) = 80%
Option of Voluntary Coupled Support (VCS) = 80%
Option of Areas with Natural Constraint (ANC) = 76%
Scottish regional rates = 76%
Option of Young Farmers (YF) scheme = 76%
Use NR to help YF = 68%
The strongest agreement (More than 66% agreeing with question and where number
of strongly agree responses was greater than agree responses):
•
•
•
Minimum activity for payment = 89% (58 strongly + 31% agree)
Option of VCS = 80% (43% strongly + 37% agree)
Scottish regional rates = 76% (45% strongly + 31% agree)
Agreement (50 – 66% of responses agreeing with the question)
•
•
•
•
•
Option of Small Farmer (SF) scheme = 64%
Active farmer (5% income + min activity) = 64%
Use of NR to stop land abandonment = 59%
Progressive capping = 57%
Internal convergence = 53%
Strongest disagreement (more than 66.6% of responses disagreeing with the
question)
•
3 crop diversification requirement (73% responses disagree)
Disagree (50 – 66% of responses disagreeing with the question)
•
•
•
•
30% funding for greening = 61% disagree
Maintain permanent grassland = 58% disagree
7% Environmental Focus Areas (EFA) requirement = 56% disagree
€5000 derogation from min activity = 56% disagree
Questions eliciting highest number of neutral answers
•
•
•
VCS limited to 5% = 34% of responses were neutral
Pillar 1 (P1) to Pillar 2 (P2) flexibility = 24% of responses were neutral
P2 to P1 reverse flexibility = 24% of responses were neutral
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•
•
NR used to stop land abandonment = 22% of responses were neutral
Simplified procedures for SF = 20% of responses were neutral
Note: there may be several reasons why neutral types of answers have been
elicited. For example, a respondent may not understand the precise detail of a
particular issue or they may have felt that a particular proposal from the Commission
either went to far or did not go far enough.
Some observations – 1) Greening
•
•
•
33% of responses agree with the Commission’s proposal that 30% funding
goes towards Greening the CAP and a similar percentage agrees with 7%
EFA.;
28% of responses agreed with requirement to maintain permanent pasture;
14% of responses agreed with 3 crop diversification requirement.
This suggests that there was support for the principle of Greening but concern over
how the Commission was proposing to put the idea into practice.
Some observations – 2) Capping
•
•
57% of responses agree with the idea for progressive capping of direct
payments with 33% of responses disagreeing and 11% of responses being
neutral.
A slightly lower percentage (47%) of responses agreed that direct payments
should be capped at €300k (excluding greening payment and salaries), with
38% disagreeing and 15% of responses being neutral.
Some observations – 3) Internal convergence – flattening of payments
•
53% of responses agree with proposal to average payments within a region
by 2019, 29% disagreed and 18% were neutral.
It is difficult to draw too many conclusions from these observations, however, due to
the nature of the questions. For example, those disagreeing with 30% funding for
Greening or that direct payments should be capped at €300,000 might agree in
principle but think these figures are either too high or too low.
4.2 - Direct payments - Analysis of the questions inviting comments
The 5 opportunities to provide additional comments under Direct Payments. The
following section shows a summary of these additional comments. Comments were
not always confined to the question in hand.
Q3. What might be a suitable definition for minimum activity in Scotland?
The question attracted comments from 143 respondents. The most frequent
responses referred to stocking density or minimum cropping levels; meeting GAEC
requirements; a focus on outcomes rather than activity, area-based as opposed to
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historic payments; entitlements and new entrants; capping; land quality; public goods
and greening; income from farming activity.
Stocking density and minimum cropping - the main points made were:
• Should be a minimum stocking rate/cropping level (there were different ideas
about what this rate/level should be);
• Stocking/cropping rates should reflect land quality/capability – possibly needs
to be defined at regional level not Scotland level;
• Should include compliance with animal welfare and farm assurance;
• Should be minimum numbers of livestock on the farm.
Meeting GAEC requirements - the main points made were:
• GAEC should include very extensive grazing systems;
• Minimum activity definition should include agri-environment participants;
• Need recognition of non market benefits.
Focus on outcomes rather than activity - the main point made was:
• Minimum activity can only be defined in terms of outcomes.
Area based payments as opposed to Historic payments - the main points made
were:
Timing
• Quick transition to area based payments;
• A small minority favoured a lengthy transition.
Historic
• The majority favoured a move to area based payments;
• Small minority opposed such a move.
Entitlements and New Entrants - the main points made were:
• Link between entitlements and new entrants (NE) recognised with a need to
safeguard the position of new entrants;
• Need to identify appropriate activation date;
• Age limit for new entrants was contentious;
• Entitlements should not be traded.
Capping - the main points made were:
• The capping level should be lower;
• A capping level is required.
Land Quality - the main points made were:
• Payment should reflect land quality/regional variation;
• Definition of a region was critical - avoid “averaging”;
• Need to consider market and non market factors.
Public Goods and Greening - the main points made were:
• All farmers must comply with greening;
• Need to focus on rewarding environmental services arising from land
management where the market fails to do so;
• Payments should be based on delivery of public goods;
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•
Providing economic benefit to the community.
Active farmer tests and percentage income from farming activity - the main
points made were:
• A definition based on a minimum percentage income from farming (e.g. 50%
and 60% was suggested);
• Should be based on farm accounts.
Other points made by respondents included
• Tenant/landlord relationships;
• Move from universal income support to targeted payments;
• Link payments to food production;
• Minimum farm size.
Q12 Do you have any further comments to make on “Section 1: Basic
Payments”?
The question attracted comments from 123 respondents. The most frequent
responses referred to the 2011 eligibility rule; historic versus area based payments;
transition to area based payments; activity and capping.
2011 eligibility rule – the main points were:
• Large number of comments – many linked to new entrant issue;
• Evidence of farming activity should be enough to qualify for entitlements;
• Discriminates against active farmers who had no entitlements in 2011;
• Discriminates against new entrants;
• Entitlements should not be just for young farmers - should be no age
discrimination;
• Some support for double gate principle but based on proof of activity not
necessarily activation of entitlements.
Transition to area based payments – the main points made were:
• Majority of comments fell into two camps of roughly equal numbers i.e. –
o those calling for move to 100% area basis on day 1, and;
o those who thought there should be a transition period but that this
should be faster than that proposed.
• A minority said historic element of Basic Payment should be higher than 60%
at start of scheme and that transition period should be longer than that
proposed.
Historic versus area based payments – the main points were:
• Most supported a move away from the historic basis for payments to area
based payments e.g.
o Historic payments are no guarantee of future activity;
o Historic payments are a barrier to entry and should be phased out
sooner rather than later.
• A minority supported retaining historic payments.
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Activity – the main points were:
• All active farmers should be entitled to payments;
• Slipper farmers shouldn’t get payments;
• A few said there should be no automatic derogation for those receiving
<€5,000 e.g. all farmers should be subject to the same requirements.
• Many were opposed to the 5% income test e.g.
o Expressing concern about the impact on farms that had diversified;
o Saying it would discriminate against new entrants who have to borrow
or generate external income to get established;
o Active farmer definition should be about activity not income.
Capping – the main points were:
• Lot of support for capping in principle although not necessarily the detail;
• Quite a lot of those who supported capping said the capping maximum should
be lower e.g. €100,000 or €50,000;
• Some said capping should start at a lower level;
• Quite a few said they preferred compulsory modulation with a shift of funds to
P2 to capping;
• A minority were opposed to capping;
• Capped funds should go to the National Reserve.
Other points made by respondents included:
• Quite a few were in favour of regionalisation in principle (very few who
commented were against);
• Some supported a shift in support towards the poorer quality land (best land
shouldn’t need as much support);
• No trading of entitlements – entitlements should transfer with land or go to
fund National Reserve;
• Some support for VCS.
Q20. Are there any other criteria you think should be included under greening?
Overall, there were 94 responses to this question. As well as more general
responses about greening, the most frequent responses referred to ecological focus
areas (EFA); 3ha threshold; permanent pasture and carbon emissions.
Greening - the main points made were:
• More of those who answered this question supported than opposed the idea
of greening;
• Those opposed often said that Scottish farmers were green enough or that
greening should be carried out under Pillar 2;
• Need to focus effort to those areas best able to deliver benefits i.e. through
regionalisation/land type;
• Need to ensure farmers are given credit for areas of the farm that are already
“green”;
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•
•
•
•
Many responded that membership of agri-environment agreements should not
count towards greening (minority responded that they should);
Proposals too restrictive – need more flexibility;
Scottish Government should call for a menu of options;
Small farmers shouldn’t be exempt.
Ecological focus areas (EFA) - the main points made were:
• Semi natural areas, grasslands and woodland to be included in eligible area;
• Minimum EFA area should be 10% (although some thought 7% was too high);
• Existing agri-environment areas should count towards EFA;
• Should be options to allow farmers to work together to link EFAs across
landscape;
• Should include overwinter stubbles/cover crops.
Crop diversification - the main points made were:
• The proposed 3 hectare threshold is too low;
• Uneconomical to grow three crops on such a small arable area.
Permanent grassland - the main points made were:
• Need to maintain long rotation reseeding in Scotland;
• Use definition to protect areas of ecological significance;
• Keep permanent grassland rules in cross compliance;
• Definition must include heather.
Carbon emissions/climate change mitigation - the main points made were:
• Use minimum tillage;
• Use of forestry;
• More efficient use of resources should be considered;
• Reduction in fossil fuel usage.
Other - the main points made were:
• Addressing fuel use on farms;
• Compulsory soil testing to ensure appropriate targeting of fertiliser;
• Water course protection.
Q24. Do you have any further comments on "Section 2: Further schemes
which Scotland would have to offer"
Overall, there were 94 responses to this question. The most frequent responses
referred to national reserve; new entrants; small farmer exemption; greening; the 3
crop rule and permanent grassland.
National reserve - the main points made were:
• Strong link with new entrants’ needs;
• Categories other than young/new entrants should benefit;
• 3% is insufficient to fund NR;
• NR must be on-going.
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Young Farmers Scheme - the main points made were:
• Should be a new entrants scheme – no age discrimination;
• Should be for new farmers regardless of age;
• 54ha limit is too small.
Small Farmer Scheme – the main points made were:
• Small farmers should not be exempt from cross compliance;
• SFS payment should be higher so that small active farmers avoid
bureaucracy;
• Even smallest crofts, e.g. 1ha, should qualify.
Greening - the main points made were:
• Need for flexibility within Member States;
• Greening must deliver across all farmland;
• Use GAEC rather than duplication through 30% of budget.
3 crop rule - the main points made were:
• Unsuitable in much of Scotland due to climate, soil type etc;
• Could be negative consequences for the environment.
Permanent grassland - the main points made were:
• The 5 year rule does not fit well with the permanent grassland rotation in
Scotland – lot of respondents suggested figure should be higher e.g. 8 or 10
years;
• Long term reseeding must be allowed to maintain productivity.
Other - the main points made were:
• One size does not fit all.
Q31. Do you agree there should be an option to allow the transfer of up to 5%
of Rural Development funds from Pillar 2 to Pillar 1 where Pillar 1 payment
rates are currently less than 90% of the European average rate?
Overall there were 84 responses to this question. Respondents were split roughly
50/50 about whether they agreed or disagreed with the proposal. The most frequent
responses referred to a need for flexibility.
Respondents that agreed with the proposal - the main points made were:
• Flexibility – value of having the option;
• More payment to food production;
• Good if the money could be used to support Beef Calf Scheme.
Respondents that disagreed with the proposal - the main points made were:
• No logic to this and inconsistent with Scotland arguing for greater share of
Pillar 2 funds;
• Already insufficient funds in Pillar 2;
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•
•
Any transfer of funds should be in opposite direction;
Pillar 2 produces public goods with public money.
Q32. Do you have any further questions you wish to make on this section?
Voluntary Coupled Support (VCS), ANC and transfer between Pillars
Overall there were 52 responses to this question. Respondents commented on the
various optional schemes set out in the Commission’s draft Regulation.
Voluntary Coupled Support - the main points made were
• Could be one way of protecting and sustaining farming systems that are
delivering high environmental benefits;
• Should be used to support extensive livestock grazing in High Nature Value
farming and crofting;
• Scotland should push for 10% to be used for VCS (not 5% as proposed);
• VCS should be used to support sectors other than beef e.g. deer, sheep;
• Provide financial incentive for rare/ancient breeds.
Area of Natural Constraint - the main points made were:
• Support for ANC in principle but less consensus about whether support would
be best under Pillar 1, Pillar 2 or both;
• If ANC in P1 there was concern about complexity and conflict with P2 ANC;
• Payments need to be regionalised;
• Call for mountain and island categories.
Transfers between Pillars - the main points made were:
• Some support (though not universal) for transferring funds from P1 to P2 to
increase spending on agri-environment measures;
• No support for “reverse modulation” (P2 to P1 transfer);
• Lot of support for ensuring Scotland gets fairer share of P2 budget.
4.3 – Rural Development Main Findings
There were 79 responses on the Rural Development Regulation. Due to the smaller
sample size the analysis of these responses cannot be used to give a definitive
Scottish view and as such the detail below should be seen as information only. Of
those that responded using Questback, 35 said their main interest was farming, 15
had environmental interests with the remainder having food, forestry, other business
and community groups interests. 14 classed themselves as other which included
public sector and had an interest across all categories.
For each of the four tick box questions, the majority of the responses fell into the
agree/strongly agree category and the percentages are shown below:
• Do you agree with the objectives and priorities of EAFRD (European
Agricultural Fund for Rural Development) as set out at article 4 and 5? = 79%
• Do you agree with the proposals regarding thematic sub-programmes which
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are set out in article 8 and annex III? = 68%
• Do you agree with the proposal re LEADER in articles 42 – 45 and the
proposed minimum spend of 5% of budget set out in article 65(5)? = 71%
• Do you agree with the proposal that EAFRD comes under a Common
Strategic Framework (CSF) as set out in the CSF regulations? = 79%
4.4 - Rural Development - Analysis of the questions inviting comments
Respondents were invited to comment on the measures which the Scottish
Government are able to choose investment priorities from. A summary of the
comments received for each measure is given below; where the measure is not
listed no comments were received. It should be noted that the majority of comments
received were on what we will actually do under our next Scotland Rural
Development Programme, rather than comments on the proposed European Rural
Development Regulations, however these have been included as the purpose of this
report is to reflect the comments received.
General comments may have come from one or more respondents, where multiple
respondents gave the same comments, this is highlighted.
Q. Comments on the specific wording of the measures which Scottish
Government are able to choose investment priorities from.
Article 15: Knowledge transfer and information actions
Potential beneficiaries of this measure should be widened, and the sectors covered
should also be increased to include environmental and game management training.
It was also highlighted that there should be an integrated approach which could be
linked with cross compliance and direct payment requirements.
Article 16: Advisory services, farm management and farm relief services
It was questioned whether multiple access to this measure was permitted. It was felt
that the potential beneficiaries should be widened. In addition environmental,
historic environments and landscape scale conversion advice should be included.
Article 17: Quality schemes for agricultural products and foodstuffs
The focus should be widened to include environmental, biodiversity and forestry
standards with no time limitation. Other respondents questioned the value of this
measure.
Article 18: Investments in physical assets
Should be inclusive of wider rural development, rather than only agriculture. Should
be for the promotion of progressive farming and to include pollution control and
management of slurry systems.
Article 19: Restoring agricultural production potential damaged by natural
disasters and catastrophic events and introduction of appropriate prevention
actions
Should include forestry and support for heather beetle and overgrazing of heather. It
was highlighted that this was an unpredictable, and potentially expensive measure.
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Article 20: Farm and business development
Should include training facilities and recycling.
Article 21: Basic services and village renewal in rural areas
Three respondents felt that non-public bodies should be included as potential
beneficiaries. It was suggested that the title should include reference to
infrastructure and the use of management plans, and reference to Local Nature
Conservation Sites should be included.
Article 22: Investments in forest area development and improvement of the
viability of forests
Should include support for production of forest management plans and forest
thinning. Environmental considerations should be included.
Article 23: Afforestation and creation of woodland
More detail and clarification was required, while environmental considerations should
be included. It was also requested that income forgone payments were reinstated
and the measure should include establishment and maintenance of woodland by
natural colonisation.
Article 25: Prevention and restoration of damage to forests from forest fires
and natural disasters and catastrophic events
Further clarification was required on what can be supported through this measure.
Article 28: Setting up of producer groups
Organic farming should be prioritised
Article 29: Agri-environment- climate
Eleven respondents felt that 25% of funds should be allocated to this measure, and
two respondents felt this measure should be prioritised or compulsory. Recognition
must be given to commitments that could be made for climate mitigation and
adaption in agricultural landscapes e.g. relating to habitats such as high nature value
grassland and peatlands.
Article 30: Organic farming
Two respondents felt it should be compulsory to include this measure.
Article 31: Natura 2000 and Water framework directive payments
Should be prioritised and include capercaillie and black grouse.
Article 33: Designation of areas facing natural and other specific constraints
An ecological services approach should be adopted which incorporates biodiversity,
landscape, cultural heritage, recreation and community benefit. Six respondents felt
this measure should support High Nature Value farming and crofting systems, and
maintain extensive livestock grazing. It was highlighted that the mountain areas
definition does not reflect conditions in Scotland
Article 34: Animal welfare
Should include medicated grouse grit.
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Article 36: Co-operation
Should be widened to include social enterprises, local NGOs, third sector and civil
society organisations. Should include landscape scale co-operation, while organic
farming should be prioritised.
Article 37: Risk management
Ten respondents felt this measure should be deleted.
Article 38: Crop, animal, and plant insurance
Ten respondents felt this measure should be deleted.
Article 39: Mutual funds for animal and plant diseases and environmental
incidents
Ten respondents felt this measure should be deleted. Should include sheep dipping
strategies and healthier beetle management
Article 40: Income stabilisation tool
Ten respondents felt this measure should be deleted.
Article 55: National Rural Network
Focus should be widened from agriculture to rural enterprises.
General comments on measures
There was a keenness for a simple structure with consistent wording. Many
respondents highlighted the need for collaborative working across all actors that
takes local strategic planning and development into account. A holistic approach at
landscape scale that is driven by an ecological service approach has also been
suggested. While the EU priorities were supported, there was a keenness to retain
flexibility to allow Scotland to translate these priorities into specific actions, supported
by evidence based assessment.
Q. Comments on the Common Strategic Framework
There was general support for a Common Strategic Framework with a need to
ensure that this adds value and does not just add another layer of bureaucracy.
More information is required to prevent confusion, and to clarify how priorities, sub
priorities, axes and funding streams link together. A number of respondents felt that
local decision making and targeting of funds was important, with more LEADER-style
bottom up approaches.
Other comments on European Commission Rural Development reform
proposals
The objectives were supported, the emphasis on knowledge, learning innovation and
co-operation were welcomed. However, simpler, non-competitive schemes were
sought. There was concern about the impact of reduced budgets, and the bridging
between programmes.
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A number of priority areas were suggested: delivery of public goods; Scotland’s food
and drink industry; agricultural land to be protected and worked; sustainability of
natural resources and climate change; landscape and the historic environment;
infrastructure investment by farmers; and, sustaining rural communities. Further
comments were received on individual measures including greater use of LEADER,
reinstating competitiveness of forestry and prioritising infrastructure investment by
farmers.
Finally, it was suggested that there should be provision of environmental and
landscape information to land managers which should form part of the cross
compliance requirements; and the public should be able to see farm environmental
maps.
4.5 – Horizontal Finance and Control Regulation Main Findings There were 67 responses on the Horizontal Regulation - considerably fewer than the
responses on Direct Payments. Due to the smaller sample size, the percentage
analysis should be treated with caution. Of those that responded using Questback,
30 respondents said their main interest was farming, 14 had environmental interests
with the remainder having food, forestry or public sector interests.
The analysis of tick box questions shown below makes no distinction between
organisational responses and individual responses.
Strong agreement (More than 66.6% of responses agreeing with question):
•
•
•
•
•
Payments available in Euros = 70%
Availability of online application systems would aid accuracy and timeliness of
processing = 79%
Expand and target Farm Advisory System = 71%
Holistic approach to inspections = 81%
Monitoring and Evaluation should be all embracing and apply to direct
payments, market measures, rural development and cross compliance = 78%
Agreement (50 – 66% of responses agreeing with the question)
•
•
In favour of an advance and final payment of Direct Payment = 60%
Sustainable Use of Pesticides should be included in cross compliance = 66%
Strongest disagreement (more than 66.6% of responses disagreeing with the
question)
•
Exempt participants in small farmers scheme from cross compliance penalties
= 73% disagree
Disagree (50 – 66% of responses disagreeing with the question)
•
Remove requirements relating to wild birds (SMR 1) from cross compliance =
57% disagree
17
•
Remove requirements relating to protected plant species (SMR 5) from cross
compliance = 56% disagree
Questions eliciting highest number of neutral answers
•
•
•
•
Remove requirements relating to certain animal diseases = 34% neutral
Remove requirements relating to sewage sludge = 25% neutral
SG should advance submission date of SAF = 30% neutral
LEADER expenditure should be paid out by SGRPID = 36% neutral
Some observations – 1) payments and submission of SAF (Single Application Form)
•
•
88% of responses were either neutral or supportive of LEADER expenditure
being paid out by SGRPID (Scottish Government Rural Payments and
Inspections Division).
95% of responses were either neutral or supportive of payments being
available in Euros
Some observations – 2) cross compliance
•
The majority supported bringing the Water Framework Directive and the
Sustainable Use of Pesticides Directive within cross compliance. Also a
majority were against removing the protection afforded to wild birds and plant
species. There was no clear view on of the proposed changes e.g. on animal
disease, sewage sludge, machinery use on soils, burning stubble, protection
of wetland and carbon soils, with almost equal numbers both for and against.
4.6 - Finance and Control - Analysis of the questions inviting comments
Q. Do you agree that the impact of the CAP should be measured against the
three objectives shown? Objectives are:
a) viable food production, with a focus on agricultural income, agricultural
productivity and price stability;
b) sustainable management of natural resources and climate action, with a
focus on greenhouse gas emissions, biodiversity, soil and water;
c) balanced territorial development, with a focus on rural employment,
growth and poverty in rural areas.
The majority of respondents who expressed an opinion supported the view that the
impact of the CAP should be measured against the three objectives shown.
However, there were a variety of views expressed. Some suggested that the focus
should be on food production while others suggested that food production should be
left to the market and that the focus of CAP should be on (b) and (c). Some wanted
the objectives to mention the historic environment and to make a more overt
reference to forestry. Some questioned how it would be measured.
Q. Please comment on specific SMR's/GAEC's you would wish to include or
remove
18
A range of views were expressed ranging from suggesting the removal of a number
of SMRs and GAEC measures from cross compliance to retaining and adding to the
current measures. Some common themes included concern about the agricultural
impact of the proposed GAEC measures protecting carbon soils and wetlands,
including the ban on first ploughing and a ban on burning stubble. Some suggested
that the GAEC measures relating to encroachment of vegetation should be relaxed
in order to recognise the environmental benefit of scrub. There was support for
including the Water Framework Directive and the Sustainable Use of Pesticides
Directive within cross compliance, and some support for extending the protection of
historic and archaeological sites within cross compliance. Some suggested that
enforcement of cross compliance should be strengthened.
Q. What changes, if any, would you like made to the cross compliance penalty
regime?
Comments fell into 2 main camps – those that suggested the penalty regime should
be more proportionate by, for example, reducing or removing penalties for minor
breaches, and those who felt that the regime should be strengthened in particular for
breaches of environmental regulations and GAEC or for repeat offenses. The latter
group also called for effective enforcement and talked about “incentivising”
compliance.
5 - Conclusion
There was a good response to the three consultations, in particular the one on direct
payments. The responses have been, and will continue to be, useful for informing
the Scottish Government negotiating position within the UK and in Europe. There
were few surprises in the responses overall – a fact that reflects the high level of
engagement the Scottish Government has previously had with stakeholders on CAP
reform.
While the views of the different interest groups were at times polarised, for example,
regarding what should be in or out of GAEC, there was a also lot of consensus.
There was a lot of support for setting a minimum activity requirement, that all active
farmers should receive direct payment entitlements and that those in the Small
Farmers Scheme should be subject to cross compliance. Rural development
respondents highlighted the need for inclusivity and the widening of focus beyond
purely agriculture oriented activities.
“Flexibility” was a word that cropped up regularly in the comments boxes across all
three consultations. For example, direct payments respondents wanted the greening
proposals to be more flexible; rural development respondents wanted Scotland to
have the flexibility to select options on the basis of national priorities; and finance
and control respondents wanted Scotland to have more flexibility to decide the
appropriate level of penalty that should apply to breaches.
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6 - Feedback
This was the first time the Scottish Government had used an on-line Questback
survey to consult stakeholders on the CAP. Feedback from stakeholders has been
quite positive with most finding it accessible and easy to use. The main criticism has
come from organisations that found the Questback survey too restrictive for their
purposes. In particular, the limited space for comments was criticised. However,
that said, most users made very economical use of the comments boxes - comments
were therefore more concise and focussed than they might otherwise have been.
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ISBN: 978-1-78256-205-4 (web only)
The Scottish Government
St Andrew’s House
Edinburgh
EH1 3DG
Produced for the Scottish Government by APS Group Scotland
DPPAS13560 (10/12)
Published by the Scottish Government, October 2012
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